20250121Petition for Reconsideration.pdf

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100*
ST8 NERIDGE
CDS StoneRidge
Utilities, LLC
P.O. Box 298
Blanchard, ID 83804
Ph(208) 437-3148 Extn. 4
SENT By: Email tECEIVED
i uesaay, January 21, 2025
January 17, 2025 IDAHO PUBLIC
UTILITIES COMMISSION
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
RE: CDS StoneRidge Utilities, LLC Corrected Renewed Petition for Reconsideration &
Clarification—SWS-W-24-01
Plea;e find attached our Corrected/Renewed Petition for Reconsideration & Clarification
For SWS-W-24-01.
PleaWarupih
you have additional requests or questions.
Sinc
Chan
Managing Member
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 1 of 52

Chan Karupiah
CDS StoneRidge Utilities, LLC
P.O. Box 298
Blanchard, ID 83804
[e-mail]
Managing Member CDS StoneRidge Utilities, LLC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF CDS CASE NO. SWS-W-24-01
STONERIDGE UTILITIES, LLC., RENEWED PETITION FOR
FOR AUTHORITY TO INCREASE RECONSIDERATION
ITS RATES AND CHARGES FOR ND CLARIFICATION
WATER SERVICE IN THE STATE
OF IDAHO
Pursuant to the Commission's Rule of Procedure 331, IDAPA
31 .01.01.331, Idaho Code § 61-626, and the inherent authority of the
Commission, CDS StoneRidge Utilities, LLC.,. ("StoneRidge" or
"Company") files this Petition for Reconsideration and Clarification of
Corrected Order No. 6407 entered on December 24, 2024.
BASIS FOR RECONSIDERATION/CLARIFICATION
Petition Review Legal standard:
The Commission has broad discretion to set rates. But that
discretion is not boundless. The Commission must make factual
findings, sufficient to enable judicial review, that are supported by
evidence in the record. Wash. Water Power Co. v. /daho Pub. Utiis.
Comm n, 101 Idaho 567, 575-76 (1980) (overturning Commission
decision that lacked sufficient factual findings). The Commission must
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 2 of 52

acknowledge and address issues that impact a utility's opportunity to
earn a fair rate of return, including regulatory lag in environments of
high inflation and large capital expenditures. Utah Power& Lightco. v.
Idaho Public UNIs. Comm n, 102 Idaho 282, 284-85 (1981)
(overturning Commission's decision to remove an attrition adjustment
to account for regulatory lag, despite evidence of excessive regulatory
lag due to high inflation and large capital expenditures). And the
Commission must adjust test year data "where the changes are shown
to be reliable and certain" and include within rate base "all items which
are proven with reasonable certainty to be justifiably used by the utility
in providing service to its customers. 'Utah Power & Light co., 102
Idaho at 284.
Timeliness of Petition for Reconsideration and Clarification filing due
date.
The Company has twenty-one days 21 days after the Order was
received to file their "petition for reconsideration and clarification".
The Company filed their initial Petition on December 20, 2024, 21 days after
receiving ORDER NO. 36407 on November 29, 2024.
The Company prepared the initial submission without yet receiving Excel
Exhibits that are referenced on page 57 of ORDER NO. 36407. The
Renewed Petition for Reconsideration and Clarification was filed on January
14, 2024. The Excel Exhibit from the original ORDER NO. 36407 was
received by the Company on December 24, 2024.
Even though we requested the missing excel file from the Staff we did not
receive the file before our original Petition Filing deadline. Nonetheless we
filed by the original Petition Filing deadline. Four days later the
commissioned issued a Corrected order addressing the missing files and set
a "new petition filling deadline" of January 14, 2025 even though that 21 day
period contained only 15 working days after holidays and weekend days. We
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 3 of 52

are filed our Renewed Petition for Reconsideration and Clarification on
January 14, 2025. This "Corrected" Petition for Reconsideration and
Clarification is being filed on January 17, 2025.
Statement by Company regarding the Staffs and Commission's categorizing
the Company as a small Water Company and thus being subjected to the
IDAPA presumptions of small water companies;
Staff and Commission both consistently refer to the Company as a Small
Water Company as defined under /DAPA 31.35.01Po/icies and
Presumptions forSmaii WaterCoinpanies. The Company has currently 340
residential/commercial customers and the equivalent of 569 residential
customers. In 2023, the Test Year, the Company produced total revenue of
$260,000+. The Company interprets Idaho Law and Regulations that CDS
StoneRidge Utilities is in fact not a small water company per Idaho
regulations. Yet Staff and the Commission both repeatedly cite the
Company's status as a Small Water Company that is subject to Idaho Rules
and Regulations for Small Water Companies including the presumptions that
any capital investments made are Contributed Capital and not to be part of
the rate base calculation, in other examples below, the IPUC cites these false
presumptions as justification for denying leases of office space, equipment,
water rights, and other property rights, etc.
Statement by Company/ regarding low-level of Collaboration
between Staff and the Company on this General Rate Case.
Staff has consistently stated and reminded the Company that "related
party transactions" are subject to a "greater scrutiny when making prudency
determinations". The Company has responded to Staff requests for
additional documentation by providing all items available: As a Water
Company making their first General Rate Case application in the five years
we have operated CDS StoneRidge Utilities, LLC., one of the biggest
challenges we have faced is when we have experienced a lack of
collaborative exchanges between Staff and the Company when it comes to
our providing sufficient information to Staff for the issues we are working on.
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 4 of 52

Given the large amount of time, money and energy that a Water
Company invests in a general rate case, it would behoove both the Company
and Staff to attempt to resolve, prior to deadlines, all instances where Staff
has determined that the documents provided are not sufficient to Staff's
purposes. Thus, it is puzzling to us that Staff after receiving information and
reviewing the submitted information and finding it insufficient, that Staff does
not reach back out to the Company and inform the Company that their
submission is not sufficient and request more specific information that Staff
is seeking on a matter. The effect of this lack of collaboration within the IPUC
Case process with the Company seems to always lead to these specific
issues either being denied or increased/decreased significantly to the
Company's detriment.
The Company finds this issue to be a significant fault in the IPUC
controlled procedures by which our case has been processed. Given the
relative difference in power positions and Case processing experience of the
IPUC and the Company, this lack of collaboration can only be perceived as
a detriment to a private water company's economic survival. The existing
process is neither efficient nor equitable to the regulated IPUC Water
Company. Rather the impression is that the goal is to maintain the status
quo for customer pricing with little concern about the economic well-being of
the privately owned Water Company.
Typically, in these situations, Staffs inappropriate and Customer-
centered approach to denial of documentation submitted by the Company for
Staff Review is to wait till the final report/ORDER to inform the Company their
submitted documentation is not sufficient. We typically hear we are welcome
to address the matter in a future rate case—this may be too late or even fatal
for the operator of a water company that is already in perilous condition.
"Oh well, you can always address this in a future rate case"!
in addition to the lack of collaboration between the Staff and the
Company, the Company is unaware of any instances where Staff made a
direct request to examine the books and records of any of the Company's
related party entities—i.e. accounting/billing programs, bank records and
bank statements, in which the Company did not respond to the Staff request.
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 5 of 52

Yet, some Staff have made some statements that seem to imply Staff has
seen some individual records (i.e. employee payroll records) from the related
Companies when, in fact the Company is unaware of how that is possible
when Staff has never requested access to any of those records.
Company suggestion for increasing the level of collaboration on
this case and similar rate cases going forward:
1. The Company proposes that starting with this Petition for
Reconsideration/Clarification, the Commission and the Company agree
to jointly meet remotely to discuss issues where the Company's provided
support/documentation is found insufficient by the Commission. The
objective of these meetings would be to have the Staff, and the Company
discuss alternative/additional documentation that Staff would accept as
sufficient. This joint approach to resolving issues would be much more
effective use of time and resources for both the Commission and the
Company, which in the long term will be of the highest value to all
involved, including our Water Customers!
2. The Commission needs to stop "keeping to themselves" their
determination that they want additional information from the Company.
This information should be disclosed to the Company as soon as Staff has
reached their decision. Rather than waiting until the Publishing of Staff
Comments and the Commission ORDER.
This strategy/tactic only serves to raise the costs of the Company through
"Regulatory Lag" by passing the buck to a future IPUC case. And by
default, this same strategy/tactic delays the reasonable increases in
Customer bills over time. These types of delays made by the Commission
can conflict with the Commission's charge
The main elements in fixing reasonable rates for service rendered by[a]
public utility are the cost of rendering service on an economical and
efficient basis, fair return to the utility on its property used and useful in
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 6 of 52

such service and fairness to the public. "Intermountain Gas Co. v. Idaho
Public Uilities Commission, 97Idaho 113, 540 P.2d 775
Examples of insufficient Collaboration between the Company and Staff
regarding evidence provided by the Company to Staff during the Discovery_
process.
1. Transfer of Water CompanyAssets to Esprit after c%se of purchase
from Bridge Partners in November2018.-
2. Land, ROW, Easement and Water Right Leases:
3. Property & Casualty Insurance Premium sp/it between related
companies.
4. Lease of Office Space and Equipment from Esprit to the Company
5. Integrity Management Licensed Operator Contract.•
6. Rate Case Costs:
7. Non-Recurring Charges for Reconnections greater than 31 days.•
8. Depreciation Schedule Selection.
9. ManagementAdministration & General(`A&G') Expenses
10. Backhoe lease Expense
11. CPI Guidance for Base Rate Setting
12. Treatment of Intercompany Accounts Payable of$207,,000.00 for
end ofyear2024.
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 7 of 52

Narrative detail of the above items:
1. Transfer of Water CompanyAssets to Esprit after close of purchase
from Bridge Partners in November 2018,
Staffs assertion `For example, upon purchasing the StoneRidge
water system, Esprit transferred the land that the Company's assets
are placed on, the Right of Way Easements, and the water rights
from the Stoneridge to Esprit, then leased these back to Company
at $2,000 a month. These assets were originally owned by
Stoneridge at the time JD Resort purchased the water company"
The Commission's discussion of this issue in ORDER NO. 3647
repeated the Staff's false claim even though the Company provided
Tax Return information and a copy of the Purchase and Sale
Agreement between the Company's parent company and the former
owner Bridge Partners. "Staff noted that after acquiring Stoneridge
(actually StoneRidge, Esprit moved crucial assets (e.g land,
easements and water rights) from Stoneridge s ownership, then
leased those assets back to Stoneridge at a monthly rate. Staff was
concerned that customers are now paying lease payments for
assets that belonged to the Company and were counted as
contributed capital as the system was being developed. "
The Staff never discussed with the Company that the Purchase &
Sales agreement and tax return evidence provided in the
"Company's Response to Staff Report" were not sufficient for Staff
to acknowledge their mistake in claiming the Company had
transferred assets from the Water Company to a related company
Esprit at the time Esprit purchased StoneRidge Golf Community
from Bridge Partners.
We do not want to be classified as a "Small Water Company",
therefore the presumption of many if not all assets are "contributed
capital" is not valid nor correct. The Contributed Capital decision
should have been put forth by Staff in 2007 during CDS StoneRidge
Utilities' last general rate case.
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 8 of 52

Additional Documentation from the Company—(Attachment A )are
Company IPUC Annual Reports from 2001 to 2023. These reports
commence the year that Bridge Partners purchased the Water
Company in 2001 and continue through 2018 when Esprit bought
the Company from Bridge to the most current report in 2023. It is
clear in reviewing these reports that the Company has been treating
all investments in Plant and Equipment as capital investments on
their balance sheet and not as Contributions of Capital. The
investments are in the Assets--Plant & Equipment section of the
Balance Sheet (where they are being depreciated annually) and not
in the Liability/Equity side (where they would be amortized annually
if they were being treated as Contributed Capital)
No balances during this 22+ years under Land/land rights—at no
time during the period of Bridge's ownership are there any amounts
on the balance sheet for Land/land rights, despite Staff's claim that
assets were transferred from the Company to Esprit. Neither Staff
nor the Commission has responded to the Company about this false
claim accusing the Company of "Bad Behavior". This specific false
claim is used in several of the following items to categorically deny
intercompany expenses by claiming the Contributions of Capital and
that the Company did not provide adequate documentation/support
showing that the costs were reasonable and/or actual cost. Due to
the significance of the False Claim and its impact on rate calculation,
Staff and the Commission's failure to discuss this with the Company
prior to Staff Report and Final Order highlights the bias IPUC shows
to the favor of the Customer in opposition to its charge to also
ensure the viability of the Company through its ability to earn a fair
rate of return. "Passing the buck" to a future rate case vs working
collaboratively with the Company is an example of Regulatory Lag
and disingenuous at best!
2. Land, ROW, Easement and Water Right L eases:
Following the same mindset demonstrated in 1.) above, the Staff
and Commission, without any collaboration with the Company, just
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 9 of 52

denied all of the $2,519.00/month (2023 Test Year) lease payments
from the Company to Esprit for land, ROW, Easement and Water
Rights. In addition to claiming the assets had been owned by the
Company, the Order further stated that `Even if the Company could
demonstrate that these assets should not be treated as contributed
capital, which it has not in this record, it further has not
demonstrated that the lease rate it is charging for these assets is
the lesser of market or actual cost"
This final denial was in spite of documentation (Company Response
to Staff Report Exhibit F) the Company provided showing the Idaho
Water Supply Bank short term rental/lease rates for water in the
State of Idaho Report on this issue.
The Water Rights lease for the following Water Right.
# 95-9587 (588.60-acre feet) at $23.00/AFA $13,538/year-
$1,128/month.
The 2025 rate per Acre Foot is increasing to $33/AFA or
$19.424/year-$1,617/month. The balance of the monthly lease for
other leased items of approximately $900.00/month for use of ROW
and easements over Esprit owned property that use is restricted by
these rights for Water Storage Water Tank, Water Storage
Reservoir, Well Pump House Building and underground water lines
is both reasonable and the lower of cost and/or market—See
Attachment B where a market value lease rate of$3,125/monthly for
the Water Storage Reservoir alone determined by our Commercial
Real Estate Broker recently.
Facts Provided—The Company has provided during this case the
purchase & Sale agreement (between Bridge and Esprit) along with
the Water Company Tax Return Balance Sheet for the year prior to
the acquisition of the Company by Esprit Enterprises. These both
show that Bridge Partners (the parent company selling CDS
StoneRidge Utilities, LLC, to Esprit Enterprises, LLC) sold all real
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 10 of 52

estate and water rights to Esprit in November 2018 and that CDS
StoneRidge Utilities, had no amounts on its Balance Sheet for
Land/Land Rights, nor Contributed Capital in the year prior to the
purchase by Esprit. In addition, the Company provided the current
short term lease rate for Water Right through the State of Idaho
Water Supply Bank to support the current monthly/annual lease rate
for one of the large production wells owned by the Company that is
using one of the Water Rights owned by Esprit Enterprises, LLC.
In 2018, Esprit's due diligence of the StoneRidge Golf Community
and Utility companies led to the understanding on Esprit's part that
none of the land/buildings were owned by CDS StoneRidge Utilities,
LLC, nor most of the water rights etc.
Staffs Response—after receiving the supporting documents from
the Company, Staff did not request any further details, nor
documentation. Rather, they waited until the Final Order to claim
that the documents provided were not sufficient to allow the
charging of monthly lease amounts for water rights, easement and
ROW use. The staff also stated that as a "small water company" it
is presumed that all assets are contributed capital and therefore
should not to be included in the rate base. The Company has
annual revenues of over $225,000 and over 340 customers. The
Company does not meet the criteria of a "small water company"! It
is not clear to us why or how Staff continues to use this classification
for the Company. We do not recall having been informed that we
are classified as a small water company, except by Staff in their
report and the Commission in its order.
3. Property & Casualty Insurance premium split between related
companies.
Facts Provided—The Company has provided Staff with Copies of the
master casualty/liability insurance policy /premium along with an
estimate ($4,300.00) by the Insurance Broker for this policy for an
equitable allocation of the premium for calendar year 2023b. In
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 11 of 52

response to Staff's request, the Company obtained a "standalone
quote" ($9,000,00) for the Water Company to purchase its own
policy. The Company's insurance broker has recently provided an
updated quote for the own insurance so as to eliminate the
machinations by Staff discussed below.
Staff Response—after receiving the Company's documentation,
Staff proceeded to divide the current annual Insurance premium
among six related companies owned by the Karupiahs equally—an
incorrect assumption.
Additional Documentation Provided by the Company--The
Company discussed Staff's method of assuming that dividing the
annual Insurance premium by the six related entities, did not reflect
the reality of the risk related to each of the entities, two of the
entities, are essentially shell companies that were acquired as part
of the purchase from Bridge Partners, but these two companies do
not have any current operations or employees etc. See Attachment
C for an insurance quote from the Company's Insurance Broker of
$8,605 annually for 2025 for the Company's share of the policy
Esprit will carry in 2025 for its StoneRidge Companies. This is not a
simple arbitrary calculation estimated by Staff with little or no
insurance underwriting experience claiming that splitting the cost
evenly between 6 different entities, but rather a calculation done by
an insurance industry expert calculating the cost associated with the
water Company liability risk and its property coverage only.
4. Lease of Office Space and equipment from Esprit to the Company.
Facts Provided—The Company has provided Staff with Copies of the
Office leases with Esprit for both the Water Company and Blanchard
Utility Services the StoneRidge Community wastewater provider.
These are two separate legal entities that share the Office space
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 12 of 52

and split the lease expense between them on a 60%--40% rate
based on the larger customer base of the water Company and
related larger revenue base and their use of the space.
Staff Response—Staff's response in their comments was to falsely
claim that the Company was taking the entire cost of the two
individual leases and recording it all against the Water Company's
expenses with none going to Blanchard Utility Services (sewer
company). They failed to correctly read the lease agreements and
calculate the rent for 2023—again claiming falsely that the Company
was paying all of the Office Rental annual expense. They then
proceeded to determine that the lease amount should be split 50-
50% without providing any justification for that split vs the 60-40%
we justified based on use and revenue differential. Then they
reduced the office rental expense by $13,614.
Additional Documentation Provided by the Company—The
Company obtained a comparable office rental comparable for like
space in Priest River Idaho and submitted it in response to Staff for
their review along with a copy of the-Office rental lease agreement
for BUS.
The Commission Order, once again, denied the full rental lease
amount per the Company's lease agreement with Esprit, in spite of
being provided documentation supporting the 60-40 vs 50-50 split
and a comparable office rental comparable. And once again the
Commission refers to the vague "need sufficient documentation to
support the reasonableness of the Company's position."
Just like Staff, the Staff/Commission, failed to inform the Company
that they were not accepting their documentation until the Order had
been approved and issued. Another instance demonstrating
"Regulatory Lag" by failing to collaborate with the Company so as to
allow us an opportunity to rectify the issue in this case, rather the
Commission displays another example of"Gotcha" by waiting till the
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 13 of 52

last minute and delaying the current market costs associated with
the office lease till another future rate case.
Why wouldn't the Staff call us up and say "we disagree with your
assessment—perhaps we could have educated the Staff and we may
have come to a mutually understandable agreement. To spend a
year and over $70,000 in investment on a general rate case and
come away with a .009% annual rate of increase on our rates over
17 years provides no incentive to repeat the process. The use of
the Cost Less Accumulated Depreciation model to establish Rate
Base vs Market Valuation model along with lack of collaboration to
effectively process the case both are guaranteed to be to the
detriment of the Company to be able to earn a reasonable rate of
return on their investment, which eventually will lead to the failure of
the Company to be able to replace and update their Plant and
Equipment as it wears out.
5. Integrity Management Licensed Operator Contract.
Facts Provided—The Company included a copy of the Licensed
Operator Integrity Management contract that commenced in 2024 in
its original submission/Response to Staff Requests.
Staff Response—Staff proposed establishing a monthly Contract
Operator expense of $2,035 and removing $68,355 from the Labor
& Operations expense category to reflect the retirement of our prior
operator and hiring of Integrity Management in 2024 as a contract
Licensed Operator.
Additional Documentation Provided by the Company—The
Company is providing in (Attachment D) copies of Integrity
Management's monthly invoices for 2024 and an analysis of their
billing for 2024. The Company's calculation shows that Integrity's
average monthly billing invoice in 2024 average $4,077 or $48,919
annually.
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 14 of 52

6. Rate Case Costs.
The Company's rate case expenses including employee time
spent on the case, and advertising fees were submitted with the
Company's initial application. The Company incorrectly used the
Monthly amortization ($432/mo.) of the Rate Case Expenses
instead of the Annual Amortization in the Excel Exhibits within
the Company's original Application. In response to Staff
Comments the Company provided the annual amount of
Amortization of rate case expenses (approx. $4,900) and asked
about including legal fees incurred after Counsel was retained to
respond to Intervenors etc. The Commission Order approved
$12,665 in legal fees and removed all the other rate case
expenses as having already been "Recovery for expenses due
to employees' labor has already been accounted for in other
adjustments". No documentation was provided by the
Commission Order to document the "other adjustments" just
ignoring company expenses is not putting the company's
financial health at extreme risk.
Facts Provided—The Company provided a detailed breakdown of
its Rate Case costs and amortization with the original application
And supplemented this with updated rate case costs as we
proceeded through the year. Our initial rate case costs annual
expense amortization was incorrectly submitted as the monthly
amount.
Staff Response—Staff accepted the incorrect annual amount
(which was actually the monthly amount.)
Additional Documentation Provided by the Company—The
Company informed the Staff of its error on its rate case cost
amortization calculation. In addition, the Company inquired about
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 15 of 52

including approximately $12,665 in legal costs incurred by the
Company.
The Commission Order accepted the Legal Fees to be amortized
over 3 years and denied all other case costs, including
advertising and mailing costs of approximately $1 ,475 and all
labor. The advertising and mailing costs along with direct rate
case labor costs should be added to the expenses. The
Commission never explained how/why the other rate case
expenses were not approved. "Recovery expenses due to
employees labor has already been accounted for in other
adjustments" The Commission must address these costs and
must have justification if they continue to deny them.
7. Non-Recurring Charges for Reconnections greater than 31 days.
Facts Provided—In our Tariff #4 draft (Attachment J) we submitted
subsequent to our original rate case application, we proposed that
all monthly base fees were due yearly regardless of whether the
Customer had either requested disconnection or was involuntarily
disconnected
Staff Response—Staff reviewed our initial Tariff proposal and
suggested significant changes which the Company did not closely
review until after the Order was published. In the Staff Report a 3
times monthly customer charge was proposed.
Commission Order—The Order left the reconnection fee at 3 months
for reconnections after more than 31 days. The Company, like Gem
State Water's Spirit Lake East System, wishes to implement the
reconnection charge for 31 days or more as the actual monthly base
rate that would be paid and/or to establish, as our original submittal
called for—a Year round obligation for Customer to pay monthly base
rate whether connected or not. This is important for maintaining
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 16 of 52

sufficient funding for the Company to be able to maintain its
operations, discouraging seasonal cut-offs.
8. Depreciation Expense
Staff have implied that NAURC depreciation schedules are to be
used by the Company for its plant and equipment calculations.
However, our reading of the IDAPA and IPUC regulations and rules
finds that this is not a mandatory requirement, but rather a
preference by Staff for depreciation calculations. It is our preference
to use more traditional accounting depreciation schedules for plant
and equipment-- The IRS provides guidelines for depreciable lives
of utility infrastructure under the Modified Accelerated Cost
Recovery System (MACRS). The depreciation life depends on the
type of asset and how it is classified. Here's a breakdown of
common utility infrastructure:
A. Water Utility Infrastructure
• Water pipelines, mains, and reservoirs: Typically classified as 15-
year property under MACRS (Asset Class 49.3: Water Utilities).
• Water treatment facilities: Often falls under 20-year property if it's
part of a larger plant.
• Wells and distribution systems: Generally classified as 15-year
property.
We find that Stafft's Commission's comments about the need for a
"Costly Study" to determine the depreciation schedules is likely an
excuse to extend up to 50% the timely recovery of the company's
investments in plant and. equipment that is available under the
MACRS model. The cost of reviewing the Company's Assets and
confirming the historical cost less accumulated depreciation has
been maintained by the Company since 2001 . Additionally, the bulk
of our distribution line is plastic pipes with PVC glue and they are
starting to fail after 30 years. Blow outs are becoming more
common, especially in the Happy Valley Water System that was
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 17 of 52

annexed in 2005. Choosing a 50-year life using NAURC
depreciation schedule does not equitably reflect useful of these
pipes failing at 30 years of age. It is especially burdensome that
after 20+ years of IPUC review and at least the last 5 years of the
Company using MACRS model, now the Commission wants us to
adopt a different depreciation schedule for rate cases at least—the
changing horses in the middle of the stream in this case creates
significant burden on the Company's accounting personnel to either
keep two sets of books and or "re-state" the plant and equipment
and associated depreciation records over the last 25 years.
9. Management Administration & General_("A&G"
Facts Provided—We have provided staff with information on the
accountants work for the Company as part of our contract labor
agreement which is billed from Esprit monthly to the Company. In
this category is not only our Compliance lead, but both our
bookkeeper and the Community General Manager who provides
after-hours support to customers, accounts payable management
and weekly bank deposits. We shared our contract labor contracts
our QuickBooks files/reports showing the Journal Entries for
Contract labor. We proposed that this annual expense be reduced
by $15,750 instead of $31,395 annually.
Staff Response-- Staff never asked for additional information, rather
they waited till issuance of their report and claimed they have
insufficient documentation supporting the accountant's work and
GM's work on behalf of the Company. Staff never requested any
additional information beyond what we provided, including access
to Esprit Enterprises' records, rather they waited until the staff report
to inform us, they had insufficient information. We would like Staff
to tell us specifically what they want to justify the removal of the
accountant and GM's labor expense for keeping the Company's
financial records etc., and providing after hours customer service
etc.
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 18 of 52

Commission Order—the Commission also waited till issuing their
Order to deny the supporting documentation we have provided to
Staff during this case on our contract labor costs. The labor costs
proposed by the Company are reasonable, what is not reasonable
is the Commission's claim that the Company has failed to "clearly
identify, and separate costs associated with employees who work
for multiple related entities as part of their employment". We have
made our accounting/banking records accessible to Staff during the
last year and we have provided contract labor contracts specifying
exactly what is being charged to the Company for each employee
on a monthly basis. Staff has never asked for/or reviewed related
company accounting/banking records to our knowledge. Nor have
they informed us during this case that the contract labor agreements
and accounting/banking records have not provided them with the
information they were seeking. We anticipate that a more
collaborative process before the closing of this case might lead to
resolution of this matter, rather than once again "kicking itdown the
road" to the next rate case.
10. Customer Accounts Labor Expense
Facts Provided—The Company provided the associated contract
labor agreement covering this position. We also provided all
accounting and banking information to Staff.
Staff Response—Staff proposed an annual expense of $18,966 vs
Company's $35,490 annual expense at a 80% share of this position.
Additional Facts Provided—The Company submitted that this
position, which is hourly, averages 52.50 hours biweekly. The
position pays $26/hour plus $6.50 in payroll/benefit costs for a total
of $29.50/hour for 1,365 hours per year or $40,268 dollars a year
with 80% going to the Water Company or approximately $32,214
annually. Attached as Exhibit F are copies of timecards for this
position during 2024 along with copies of the cleared payroll-checks
during 2024 for this position.
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 19 of 52

Commission—accepted the Staff's recommendation which severely
understated the annual expense for this position. We need to
discuss with Staff this situation and determine how their proposed
amount is a little more than 50% of the annual expense.
11. Backhoe Lease
The Company is unaware that the Staff has the capacity/authority
to dictate the operations of the Water Company. Our water
Company requires the backhoe for lots of uses, especially in
exploratory digging, emergency—middle of the night leak
investigation when a buried valve fails, and excavation is necessary
to deal with the situation.
The Company is not aware of any requirement that the operator of
a backhoe must be "Certified" in order to use the equipment for snow
removal. The Company, in its Response to Staff Comments,
provided written quotes from a local rental business to deliver a
similar backhoe for two days of use. Estimating the number of snow
removal days, along with any other incidental use of the Backhoe is
not possible, but a minimum of two days a month along with
immediate access is not an unreasonable amount in this situation,
especially for snow removal. We request that the $7,200 annual
rental expense for the backhoe lease remain in the budget or
provide $10,000 in annual budget for leasing and fueling the
backhoe from a rental equipment operator with is implied delays for
equipment availability, especially in snow removal periods.
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 20 of 52

12. CPI Guidance for Base Rate Setting.
The last general rate case for CDS StoneRidge Utilities, LLC., was
approved in 2007 with the base monthly rate for a 3/" meter set for
$24.00 a month. Since 2007 there have been no increases in the
Base Residential Monthly Rate of $24.00. In that same time period
CPI increases for that time period would suggest that the current
monthly base monthly rate for a 3/" meter would be $36.00 today or
a 50% increase over 17 years (a little less than 3% per year
increase) at a minimum to ensure the Company would be able to
earn an adequate return on its original investment after meeting all
of its current operating expenses. In comparison to Commission's
approved monthly base rate for StoneRidge of$27.91, not only does
not keep up with Consumer prices, but is less than a 1%-year
increase, hardly matching the rate of inflation which the Commission
states is not the Commission's duty nor charge. It is clearly obvious
to anyone with an open mind that any formula or process that fails
to allow for prices to at lease stay up with CPI is doomed to future
failure—as there will be inadequate profits/cash flow to allow the
replacement of 35+ year old infrastructure. It is either CDS
StoneRidge Utilities, LLC., is a super incredible operator able to
survive on less than .009% annual revenue increase or the
methodology in IPUC General Rate Cases is flawed and especially
with older Water Companies that have already depreciated over
80% of the Plant and Equipment on the books—The establishment
of the rate base in relationship to the historical investment less
accumulated depreciation leads to a very different rate amount than
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 21 of 52

using market value methodology for an older more depreciated
asset company.
13. Guidance for conversion of $207,000 in intercompany account
payable to long-term note payable.
At year end 12/31/2024 the Company had an outstanding basis of
$207,000.00 to Esprit Enterprises, LLC. This balance represents the
intercompany billing from Esprit to the Company for Labor, Office
Space and other items listed above. The Company intends to make
application for a new case for Issuance of Securities to IPUC in
January 2025. Because of the lack of profitably in the Company, it
is likely that the Company will continue to run at a loss in the
foreseeable future and Esprit Enterprises, LLC., is unwilling to
increase their equity position in the Company. The Company's
precarious financial state makes it essentially impossible to borrow
money without additional guarantees/collateral being put forth by
stronger parties to bolster the Company's financial profile. No
commercial lender or DEQ will loan any money to the Company
under the Pro Forma Revenue budget approved by the IPUC for
2025. In January 2025 the Company is unable to make its annual
Happy Valley Rancho DEQ loan payment of approximately
$26,000.00. The Company informed DEQ staff last week that there
were not funds available to make the annual loan payment and
requested direction from DEQ on how to proceed.
REQUEST FOR RELIEF
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 22 of 52

For the reasons set forth above, CDS StoneRidge Utilities, LLC.,
respectfully requests that Commission enter a revised or new order
authorizing Granting reconsideration on the issues listed below in
the form of a revised or new order that approved the amounts stated
by the company below such that the Company is afforded the
opportunity to earn a reasonable return on used and useful assets.
And any other relief that the Commission deems appropriate under
the circumstances.
DATED: January 17, 2025
CDS StoneRidge Utilities, LLC.
1. The Commission to Order Staff and the Company to work
collaboratively to find a common ground on these items to ensure
that both Customer and Provider's interests are respected and
protected such that the Company can continues to provide a high
quality dependable safe supply of water to the community-while also
earning a reasonable rate of return on its investment in the system.
Commission to encourage that both parties shall work to complete
this collaboration by February 15, 2025
2. Withdraw the Commission demand of Esprit to transfer assets to the
Company which the Staff and Commission have falsely accused
Esprit of transferring from the Company to Esprit after the closing of
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 23 of 52

Esprit's purchase of the StoneRidge Golf Community and Utilities
from Bridge Partners in 2018.
3. To establish a monthly lease rate between Esprit Enterprises and
the Company for the lease of water rights, easements and Right of
Ways in the following amounts—A long-term lease is recommended
t0 alleviate potential payment shock affects from the use of
alternative short-term lease terms.
a. Water Rights Lease (known change as of January 1, 2025) at
$33.00/AFA for 588 AFA or $1,617 per month (Exhibit F
Company Response to Staff Report).
b. Ground lease for use of Water Storage Reservoir, Water Storage
Tank, Well Pump House, HV Midlevel Pump House and HV
upper water storage tanks and easements for buried
infrastructure and ROW at $900/Month--substantially below the
estimated market value for just the Water Storage Reservoir land
area (Attachment B).
4. To establish an annual Casualty and Liability insurance premium
expense of $8,605.00. (Attachment C Insurance Premium Quote).
5. To establish an annual office and office furnishings lease expense
of $27,228 as originally proposed by the Company in its Response
to Staff Report. (Exhibit I in Company Response to Staff Report for
market rate office rental comp).
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 24 of 52

6. To establish an annual Professional Contract Labor Licensed
Operator expense for Integrity Management Licensed Operator of
$48,918 (Attachment D-2024 invoices and analysis).
7. To establish an annual Rate case amortized (36 months) expense
for all legal costs as well as all mailing and advertising costs to date
of $4,725 invested by the Company in the Case to date.
8. Non-Recurring Charges for Reconnections greater than 31 days.
To establish that for either a voluntary or involuntary disconnection
longer than 31 days, the Customer is responsible for paying an
amount equal to the Minimum Monthly Rate that was "avoided"
during the disconnected period.
9. To establish that use of the NAURC depreciation schedule is not
mandated by IPUC, and that the Company at its an option can use
the MACRS Deprecation Schedule for Water Utility Company
financial reporting/rate case purposes. The MACRS tables more
accurately reflect the useful life of the life cycle of the pipes in the
ground currently
10. To Establish that Management, Administration & General annual
expense be reduced by $15,750 to account for the 1 day per
week that Water Company Accountant/Bookkeeper works solely
on the Company books (Attachment E)
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 25 of 52

11 . Truck, Backhoe Lease Expense-To establish that the annual
rate for rental of the Case Backhoe from Esprit for snowplowing
and other works be set at $7,200
12. Treatment of intercompany debt balance owed to Esprit by the
Company from 2024 expenses billed by Esprit. To support that
interc pany short-term debt from operations be allowed to
con*tLong- erm Notes.
Chan Karupiah, Managing Member
CDS StoneRidge. Utilities, LLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 17th day of January 2025, 1 caused to
be served a true and correct copy of the foregoing document to the below
individuals as follows:
Email Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83220
Boise, ID 83720-0074
[e-mail]
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 26 of 52

® Email Norman Semanko, ISB #4761
Patrick M. Ngalamulume, ISB
#11200
Parsons Behle & Latimer
800 W. Main Street, Suite 1300
Boise, ID 83702
[e-mail]
[e-mail]
Attorneys for Stoneridge Property
Owners Association
® Email Brady Espeland
Ramsden, Marfice, Ealy & De Smet,
LLP
PO Box 1336
Coeur d'Alene, ID 83816-1336
[e-mail]
[e-mail]
Attorney for Condominium Owners
Association, inc.
Z Email Michael Duval
Deputy Attorney General
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]
Attorney for Commission Staff
Ran Iph Lee arrison
76 B Hower C urt
;y Email BlanU
Z
8 804
arririson.com
Chan Karupiah, plicant
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 27 of 52

Feedback on IPUC False Comments about Company
1. Management Issues
Renewed Petition for Reconsideration and Clarification:
We have provided additional Annual Report financial reports from 2001-2023 to
IPUC in our Petition Request. IPUC needs to follow the paper trail—no
inappropriate transfers occurred and there has never been an abdication of
duties of the Company to a related party. IPUC has never acknowledged its
original claim was unsubstantiated and false, rather Staff has pivoted to CAIC
issues and lack of sufficient proof by the Company for lower of market or actual
costs as justification to deny the legitimate expenses to the Company for the use
of the assets. The Company expects that IPUC will formally acknowledge in
writing the inappropriate derogatory statements regarding Company
management made by Staff in their inflammatory claims about the Company's
Management actions on this issue pertaining to transfer of assets from the
Company to Esprit Enterprises, LLC.
IPUC might have reviewed the Company balance sheet in 2007 during the last
general rate case and noted that there were no essential assets on the Company
books at that time either.
IPUC concern centered on the potential impact on Water Company operations in
the event that Esprit should experience financial challenges that might impact the
essential assets claimed to have been owned by the Company right before Esprit
closed on the StoneRidge Community purchase. Given the relative profitability
and financial position of the Company vs Esprit, IPUC's fear of a possible threat to
the Company from Esprit's unlikely future financial challenges verges on the point
of being ridiculous
Staff Report Comments:
"Staff has concerns about the management of the Company. Specifically, Staff
belie ves that the management of the Company is not properly maintaining
ownership and control of assets that are fundamental to the operations of the
Company-Staff believes that some of these crucial responsibilities are abdicated
to a related party. For example, upon purchasing the Stoneridge water system,
Esprit transferred the land that the Company's assets are placed on, the Right of
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 28 of 52

Way Easements, and the water rights from the Stoneridge to Esprit, then leased
these back to the Company at$2,000 a month"Page 5 October 2, 2024
Company Response.
"This statement by Commission staff is incorrect and not based upon available
information, rather it shows a lack of understanding of the history of the Company
and the realities of infrastructure development. The use of the word `abdicated"
rfail to fulfill or undertake a responsibility or duty'), is a strong negative
indictment against ownership/management. It also shows a complete lack of
in vestigation of the facts prior to making an inflammatory incorrect claim about
the history of the Company before and after the purchase of the StoneRidge Golf
Community and related utility company by Esprit Enterprises, L L C, in No vember
2018" Page 11 October 28, 2024.
Commission Corrected Order-
"The Commission is concerned that assets essential to the operation of the
Company are held by a related party. As a result, the Company's operations
could be impacted by matters completely outside of its control which could put
safe and reliable service to customers at risk. Regarding whom owned certain
assets prior to the 2018 transaction, the issue becomes whether those assets
should be considered contributed capital now. It is the Company's burden to
demonstrate that these assets, including but not necessarily limited to, water
rights, easements, and real property should not receive this treatment. To the
extent certain assets may not be considered contributed capital d properly
demonstrated, the Company still must demonstrate that expenses it incurs from
related parties employing these assets are faik,just, and reasonable. These
matters are discussed furtherbelow. The Commission also finds that the
Company must apply its collection practices Ina non,preferential manner'image
7, December 24, 2024.
2. Well #3 Pump Motor/Controller Board Replacement
Renewed Petition for Reconsideration and Clarification:
The new pump motor on Well #3 was installed within 2 'h weeks of its July 2024
failure, in the height of the summer season. In early August Staff congratulated
the Company employees for the quick response. It was very disappointing to later
have the Staff make the claim that, our operators actions/comments to our
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 29 of 52

Customers might have delayed the replacement of the Pump Motor There was
absolutely no delay as the result of the System Contract Operator advising
customers to be more conscious of their water use as we were down to one well
Pump (and a 35-year-old one at that) while the#3 Well Pump Motor was replaced.
It is not clear why Staff reacted so negatively to the same operator suggesting
customers should encourage IPUC support the Company in its efforts to replace
the Well Pump Motor, including helping to determining a way to pay for a
replacement pump motor that was not in the short/nor long term budget for the
Company!
Not sure what lack of transparency you observed when we provided staff(for their
review) with estimates for both the pump motor and control board replacement as
soon as they were available in late July/Early August. IPUC implies that the
Company denied or ignored requests for information/documentation on this matter.
We are aware of no written requests nor verbal from IPUC that were not responded
to by the Company. Rather it is our perception that after we provided information
to IPUC we received no feedback until weeks later typically, when comments or
orders were released and IPUC claimed the information submitted was not
sufficient, usually as the basis to deny our expenses etc. This pattern has been
consistently exhibited in this case by IPUC and demonstrates a lack of
collaboration on this case by IPUC Staff, usually accompanied by the rather smug
"You can always address this matter in your next rate case!"
We received no questions about the Pump Motor/Controller estimates from Staff
and we proceeded to have the new pump motor installed and attempted to re-use
the existing control board as the new one was back ordered. Unfortunately, the
new pump motor was more productive than the prior one and the control board
continually went offline, and we had to shut down the well awaiting a new control
board. Other than removing the sales tax from the estimates, the final invoices for
the Pump Motor and Control Board did not change from the original estimates.
Staffs implication that information was withheld from them is some kind of
bureaucratic delusion. Especially galling, to us, was the comment about being
blindsided in September that Well#3 was still not back online—the implication being
that we were attempting to hide the situation from the Staff, etc. In spite of our
intense efforts to prompt our contractors to get Well #3 back online ASAP, they
were unable to obtain the replacement Control Board till September and it required
significant modification of the Pump House electronics, both power and SCADA
systems. At that point our 2-person full-time Company team was running a "500+
customer' General Rate Case Application, attempting to get Well #3's control
board installed and brought back online, and also managing the evaluation of the
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 30 of 52

new Golf Course Well for Esprit. Well #3 came back online in early October and
has pumped continually over 3,000,000 gallons since then and has been
successfully alternating with Well #1 Pump for the last 2 months once again.
What the Staff fails to note is that at no time during this 5-month process
was customer water supply curtailed nor were there any quality issues. The
Company received the Pump Motor invoice in August, and it was paid promptly by
parent Company Esprit Enterprises so as to ensure the contractor would continue
to expedite the replacement of the Control Board—this was after all, at the height of
the summer water-use period and typically most well/pump contractors in north
Idaho and eastern Washington are "Backlogged" months if not years. Staff had the
cost of the pump motor and control board before the pump was installed as soon
as the Company received the same information. To imply that there was a lack of
disclosure or over-billing of the work and replacement parts is disingenuous at
best. As Staff well knows, the Company has lost money over the last 5 years a
consequence of system expansion, repairs and new connections. Improvements
are not able to be paid for by a company that has no positive cash flow and a billing
rate unchanged in 17 years. The only source of funding is from the related
company (12% interest) or a private lender which will be at the rate of a "hard
money lender"12% and 6 points every 6 months-12% is not an excessive rate for
an operating company with the track record and financials that CDS StoneRidge
Utilities, LLC. has experienced since being bought by Esprit Enterprises in 2018.
The bill for the Pump Motor was due when received in August, and it was paid
shortly thereafter. Esprit offered a Purchase Lease contract which would transfer
title to the Company immediately and spread the repayment over a number of
years.
The Lease agreement was disparaged by Staff as being at 12.5% interest rate
which Staff stated is excessive and not the lowest of cost or market. Given that
Staff has approximately 20 private water companies they regulate, we find it
interesting that they see themselves as experts on the marketplace for purchase
and lease financing for companies the size of StoneRidge Utilities along with its
attendant financial condition and underwriting profile. Speculation by Staff on the
financing options for the replacement Pump Motor and Controller Board is at best
presumptuous. The Company, going forward, would have expectations that IPUC
will refrain from making such unfounded accusations about the ethics of the
Company and instead work hand and hand with the company to find solutions that
are the "Highest Good for All Involved" rather than making such inappropriate
unsubstantiated claims like this.
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 31 of 52

Esprit billed the Company for two monthly lease payments for July/August. Later
those charges were reversed and regular billing resumed in October once Well #3
was fully back online. Esprit lowered the interest agreement in the lease from 12.5
to 12% in October.
Mr. Karupiah provided IPUC with a personal guarantee when he purchased the
Company in 2018. To date he and his family have invested in excess of$1,500,000
into the Company. This personal guarantee is certainly not endless, especially
after seeing how the General Rate Setting Process works and its 100% bias
towards protecting customers against higher water rates (even though a number
of them only live in Blanchard part of the year—i.e. extremely wealthy property
owners who, in recent years have experienced significant increases in their
insurance, property tax and other utility expense increases on their often multiple
homes). IPUC's rate setting process is highly likely to result in underfunding in
Plant & Equipment by the Company--the Company was unable to make is annual
DEQ Happy Valley loan payment earlier this month. The IPUC strategy of setting
rates for this Company will eventually lead to service levels deteriorating to a level
that will not meet DEQ standards.
In regard to the Pump Motor/Controller Replacement, once again IPUC, relying on
non-existent facts, demands return of all assets to the Company that were
transferred after Esprit's purchase of StoneRidge Golf Community from Bridge
Partners, back to the Company. Given that the list of those assets is zero, then
why does IPUC continue to use that rationale to attempt to "strong arm" Esprit to
do something that is based on IPUC's completely false interpretation of the facts—
do you think that repeating a lie over and over somehow will make it a truth? And
last but not least, the new pump/controller were back online in early October, yet
the Commission order 12/24/2024 implies recovery should not occur until the Well
is back online—at that point,Well #3 had been back online 10+ weeks, another
example of IPUC choosing to ignore the facts of the situation, and certainly not
contacting the Company to confirm the status of the Well in over 2 months.
Staff Report Comments:
`Additionally when the pump on Well No. 3 failed on July24, 2024, the
Company sent a notice to the customers requesting that customers
reduce irrigation until a replacement pump could be installed. See Staffs
Attachment C. The notice also stated that the Company was requesting
expedited re view and appro val by the Commission for the replacement
pump. The Company further requested its customers contact the
Commission in support of the purchase and expedited recovery of the
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 32 of 52

pump. Staff believe this may have delayed the Company's ordering of the
replacement pump for several days while it waited for the Commission
Staff to approve of the Company performing repairs/replacements that
are mandatory to pro vide safe and reliable service. Commission Staff
does not ha ve the authority to approve purchases and recovery of
equipment, and the Company is statutorily obligated to provide safe and
reliable service.
Afterwards, Staff requested that Stoneridge provide copies of the
invoices for the well pump that was purchased. The Company's response
did not include any a vidence of payment nor copies of any invoices. In its
response, Stoneridge stated `Esprit was unwilling to invest more capital
in the Company in exchange for additional equity. Esprit offered a L ease
Purchase option which The Water Company accepted."See Staffs
AttachmentD. Staff believes this response was not adequate for several
reasons. First, Esprit and StoneRidge are related parties, and the lease
agreement is not an arm s length transaction. Additionally, per Idaho
Code 61610, the Commission has right to inspect the records of a utility's
parent company and any affiliated company. . .that engages directly in
any transaction with the regulated utility which results in expenses being
incurred... Staff has the statutory right and obligation to re view
in voices to determine the appropriate recovery of plant investments, and
denying Staff access to the invoices for the new pump violates Public
Utilities Law. Third, Mr. Karupiah signed an affidavit, in Case No. SWS-
W-18-01 stating that he would use his personal funds to support the
capital needs of the Company. A lease purchase agreement may not be
in accordance with that affidavit.
Stoneridge s response included a copy of the lease with terms of
$1,200 a month for five years. Based on the initial estimates provided for
the price of the pump, Staff calculated the interest on the lease to be
12.5%, which is above the ROE requested by the Company in this case.
Because it is not fair,just, and reasonable for Karupiahs to use its other
entities to gain additional profits from Stoneridge customers, recovery of
related party transactions should be at the lower of actual cost or market.
Therefore, any interest on a lease with Esprit is not appropriate to be
included in customer rates and if recovery of the pump were allowed, it
must be the actual cost paid by Esprit. As previously stated, the
Company refused to provide invoices for the pump and the actual cost is
unknown.
Importantly, during a September 16, 2024, phone conversation
with the Company, Staff leamed that the pump was missing a drive
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 33 of 52

component making the pump non-functional. This lease agreement has
monthly lease payment beginning on August 1, 2024, before the pump is
used and useful. The Company pro vided a copy of a check dated August
30, 2024, to Stonerdge Property Management for$2,400, stating this
was for the lease of the pump. Staff recommends that the Commission
not include the cost of the new pump in rates until it is functional, the
proper invoices have been provided, and Stoneridge has full ownership.
The pump in Well No. 3, the land the Companys assets sit on, the
right of way easements, and the water rights are all fundamental assets
for the Company to pro vide its basic services to the rate payers and
should remain with Stoneridge. Should potential litigation freeze Esonts
asset, Stoneridge could potentially be in a situation where it could not
provide basic water service. Staff belle ves that this is not appropriate
management of the Company's assets and recommends that the
Commission order Esprit to transfer all assets included in the original
purchase of Stoneridge, and any asset fundamental to pro viding service
to customers, back to Stoneridge."Page 5-6 October 2, 2024
Company Response.
We And this comment by Staff to be inaccurate, upon the failure of the pump
motor we mobilized the replacement process immediately. We were not delayed
waiting to hear back from Staff, we rely on Staff forgu/dance, but we know that
the Commissioners make the final decision, IPUC auditor, Joseph Terry actually
congratulated us on getting the pump back online so quickly. So, the statement
above suggesting that we may have delayed the pump replacement process/s
comp/ete/y inappropriate for IPUC Staff to make. Subsequent issues with the
pump controller that delayed bringing Well#3 back online were a combination of
trying to re-use an existing controller to save money and unanticipated supply
chain issues that should not reflect poorly on our efforts to bring the#3 Well
pump back online ASAP."Page 17, October 28, 2024
Commission Corrected Order.-
`A July 2024 well pump failure highlighted additional issues Instead of
promptly replacing the equipment, the Company inappropriately asked
customers to reduce water use andlobb/ed the Commission forexpedited
recovery—potentially delaying the purchase of a replacement pump.
When Staff requested documentation for the purchase, the Company
revealed a lease arrangement with Esprit rather than a direct purchase.
Staff believed that this was inappropriate for several reasons including
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 34 of 52

that it violates Idaho Code§61-610's requirements for transparency from
a parent company." Page 5, December 24, 2024
"The Commission denies any recovery under the lease agreement with Esprit for
the same rationale the Commission has repeatedly discussed in this Order
regarding the Company's other lease agreements with Esprit. We must also
remind the Company that Staff has a statutory right to review the records of any
parent company related party that engages in a direct transaction with the
Company under Idaho Code§61-610. The Company's refusal to be transparent
in this regard is a sufficient reason to deny recovery for any costs that have any
material connection to Esprit because the Company has not pro vided sufficient
evidence demonstrating the costs is the lower ofmarket oractual cost. Further,
the Commission denies the Company's request for recovery for this equipment
which does not yet appear to be used and useful."Page 16-17 December 24,
2024.
3. Golf Course Preferential Treatment:
Renewed Petition for Reconsideration & Clarification
Staff and Commission noted the Water Company's preferential treatment of the
Golf Course's outstanding Payables to Esprit for water provided to the StoneRidge
Golf Course owned by Esprit. The indignation shown by Staff/Commission is a
perfect example of the cluelessness of bureaucratic creatures who can somehow
equate the facts of this situation to being worthy and appropriate of being
mentioned in such a one-sided manner in a public document without any context
being provided by IPUC!
This is a continuation of the arbitrary and capricious behavior IPUC has
demonstrated during our 5 years of regulation. Esprit has invested/loaned over
$1,500,000 directly to the water company since 2018. None of the Company's
customers, other than Esprit, have ever provided loans or equity to the Company.
Staff and Commission's concern over preferential treatment in this situation
displays the lack of real-world awareness IPUC has—allowing your biggest
customer to carry an approximate $40,000 account balance when the Company
owes over $1,500,000 in funds to Esprit can hardly reach the definition of
preferential treatment in any context!
For the most part, the delay in the Golf Course's accounting (as the Company
struggled finding an accountant over the last 4 years), was more a function of
accounting records getting setup and updated on a regular basis. Especially when
we discovered one of our other significant customers had been "underbilled" for
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 35 of 52

several years before we discovered it—this underbilling led to a major overhaul of
our billing software and operational processes. Considering the magnitude of the
offset differential between $40,000 owed by customers vs $1,500,000 owed to
customer, the last thing the Company was exhibiting was "Preferential Treatment"
towards the Golf Course. Staff's lack of real-world experience must have led to
someone thinking that this "false claim" was worthy of putting in a public record
without providing the `whole picture" context of the facts of the relationship.
Staff Comments
"Staff is also concerned about the Company's collection practices.
Stonendge has a reasonable collections po/icy that dictates first notifying
customers who are in arrears by more than$300, and increasing efforts
to collect until notice of disconnection is given and the customer is
ultimately disconnected. However, Staff noticed the golf course was
routinely in arrears to the Company by more than$300, and the
Company did not follow its policy. The golf course is owned by Mr.
Karup/ah. The Company cannot discriminately apply its policy based on
ownership and Stoneridge must follow its policy in diligently collecting
money owed, even if it means disconnecting service to the golf course."
Page 7, October 2, 2024
CoinpanV Response
Staff consistently seems to view the intercompany relationship favorably when it
benefits the customers, but then they view it negative/y when it benefits the
Company. This was due to late accounting of intercompany payab/es rather than
actual payment delinquency. Their concems about the treatment of the golf
course's past due balance seem to ignore the reality that during most of the last 5
years the Company has owed anywhere from $100,000 to o ver$600,000 to Mr.
Karupiah's interests for his continuing in vestments in the Company to pro vide
sufficient cash flow to cover net operating losses. The Company's obligations to
Mr. Karupiah's interests have far outweighed the amounts the Golf Course owed
to the Company. In 2024 the Golf Course billing has been kept current. This issue
will be moot soon, with the new rates approved and the Golf Course's new water
supply coming online in 2024 marking the end of the Company pro v/d/ng the Golf
Course with water for irrigation. Page 19, October 18, 2024
Commission Order
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 36 of 52

Additionally, Staff noted the Company shows preferential treatment in collections.
failing to enforce payment policies against the owner's golf course which was
routinely in arrears to the Company. Staff asserted that the Company cannot
discriminately apply its collection policy and disregard the Commission-approved
tariff. Page 6, November 19, 2024
4. Transfer of Essential Assets:
During the due diligence period ofEspnK9 purchase of the StoneRldge Community
from Bridge Partners, Esprit confirmed that the Company did not ha ve title to any
real estate, the majority of the water rights, and other office equipment and
maintenance equipment and vehicles. Our strategy for operating the Water
Company going forward was to increase its re venue and de velop the resources to
allow the 35+ year old operation to prepare for future system
repairshmpro vements. The first step was to increase the new connection fees and
formalize the use of assets owned by Esprit that were part of the Company's
operations-i e. ensure that the Company's future operations would not be impaired
by changes by Esprit-i e. formalize the existing month-to month use arrangement
with written longer-teen leases, Inherent in the creation of the lease agreements
is the establishment of reasonable lease rates at fair market values etc.
Both Staff and Commission expressed concem that Esprit transferred essential
assets that were owned by the Company in 2018 to Espnt's ownership after the
closing ofthe purchase of StoneRidge Golf Community by Esprit Enterprises, L L C.!
IPUC might have reviewed the Company balance sheet in 2007 during the last
general rate case and noted that there were no essential assets on the Company
books at that time either. In our Renewed Petition for Reconsideration and
Clarification we submitted IPUC Annual Reports from 2001 through 2023 which
also prove that there are no essential assets on the Company books back to the
time it was acquired by Bridge Partners who sold to Esprit.
5. CAIC:
When the Company strongly challenged IPUC over the patently false statements
about the transfer of essential assets, IPUC deftly pivoted to the alternative claim
that the essential assets were likely to be contributed capital, and it was the burden
of the Company to prove that they were not Contributed Capital. This claim by
IPUC is dependent upon the classification of the Company as a Small Water
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 37 of 52

Company"per IDAPA interpretation and subject to /DAPA rules & Regulations.
The Company has requested from IPUC for clarification that the Company is in fact
a "small watercompanyoand subject to IDAPA's regulations. The Company's push
back again Small Water Company classification and the accompanying mandatory
CA IC treatment of essential assets, resulted in an additional pivot by IPUC a new
claim that the customers should not bear the cost of amortizing the costs of the
essential assets as they were most likely recovered through land development
activity profits in prior years.
6. IPUC Authority:
Commission's authority to regulate private water Companies in the State of Idaho
does, not include the ability to dictate takings to the detriment of the owner of the
Company. It is the IPUC's responsibility to prove to the Company that IPUC has
the ability/powers unsdiction to force the transfer of the essential assets from Esprit
to the Company, especially when IPUC claims of Esprit's transfer are false and
impugn Esprit's actions as bad faith etc.
7. Staff Lack of Experience in Water Comps Operations:
Staff think they are qualified to run a water company and tell us that our broken-
down pickup(Staff should ask fora ride the next time they are on site), is adequate
for our needs, especially because we don't currently have an onsite operator. Staff
recommended that monthly lease payments for the truck and the worn-out Kubota
4-wheeler are not to be included in the rate case calculation as they `are not
beneficial to our customers" Is IPUC really suggesting that our crews should
begin walking around our system that is 5 miles in length vs being able to use our
worn-out equipment by our contract operators and workers?
8. Repetition of Questionable Customer Comments:
Surely Staff and Commissioners are conscious that our Customers, like any
consumer, would rather see a price cut than a price increase. Likely these
customers understand that IPUC has developed a default bias to favor the
Customer vs the Company in many situations, apparently even if in the long run
that bias will most likely lead to a water system failure which will be a huge
detriment to both the customers and the Company.
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 38 of 52

/n reading the Staffand Commission o verview of the 236 comments, there appears
to be no recognition by /PUC that a number of comments were based upon
comments first prepared by 2-4 ringleaders who encouraged other customers to
follow the outline of the original copy and share it also with/PUC.
Se vera/of the ringleaders ha ve subsequently demonstrated both character and/or
mental disorders and two specifically have shown that it is no surprise that they
were making false and malicious claims that certainly should not have been
repeated by /PUC without serious review and editing. One, Frank Hi/l has
apparently been underpsychological care in recent months, and the second Steve
Resac, has been identified as an ex-convict who served time in California for the
physical beating of a girlfriend. /PUC Staff might want to keep in mind that their
indiscriminate repetition of Customer claims might not be a judicious strategy for
/PUC to follow.
With that context in mind, we would expect that/PUC would be careful to a valuate
customer comments about the system, the pricing, the water qua//ty and the
operating dependability of the system the Company has been running for 5+years.
The issue of high chlorine levels was mentioned in/PUC statements, said to be a
complaint by many customers who subsequently claimed to have their plants killed
and forced to install water filter etc. Yet there is no record of complaints being filed
by customers with 1PUC and DEQ, but that did not prevent Commissioners from
suggesting Staff should contact DEQ about this issue. This entire issue was
proceeded in /PUC comments by Staff reference to the recent DEQ review of the
system which found no issues with Reliability nor quality.
From Staff Report SWS-W-24-01 `Response to Staff Production Request
No. 16. Staff also belie ves there are no outstanding sanitary issues or
significant deficiencies that impedes system reliability. Additionally, Staff
concluded that there are no existing consumer complaints related to
water pressure or reliability issues during 2019 2023." Page , October
9. Owner business [practices cornment
When reading the Comments in the Commission Order on this case
there is a complete absence of any responsibility on the part of the
Commission that Staff might also be part of the issue in regards to the
claimed lack of sufficient support being provided by the Company in
making the case for primarily legitimate expenses incurred by the
Company as necessary to provide a documented dependable and safe
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 39 of 52

supply of water to 500+ equivalent customers over the last 5 years. A
remarkable accomplishment by a Company running significant annual
losses and a minimal history of experience in the Public Utility business.
There is also a total lack of acknowledgement that Staff has routinely
failed to work collaboratively with the Company on the Company's five
IPUC cases over the last five years. Not only does IPUC fail to provide
any direction about what it considers to be sufficient documentation,
Staff also routinely "sits" on documentation provided and does not
inform the Company that this documentation is no sufficient until the
Staff Report is issued. While this may not be an issue for larger water
companies with years of Regulatory experience, it is a very challenging
issue for a newer Water Company lacking regulatory experience. The
lack of 3rd Party review on these cases—absent a unrealistic option to
appeal to the Idaho State Supreme Court—leaves IPUC in the position of
being both Judge and Jury and virtually unassailable and above
reproach for behavior that is certainly not a fair and reasonable to the
regulated Water Company. And adding to this unequitable reality, are
the statements by I PUC that "you can always address this issue again in
a future rate case"and/or"Can the Company remedy this looking
forward?Possibly depending upon the quality of evidence it submits
The decision made in this case relates to the record before the
Commission."
Commission Order Comments:
As a general matter the Commission will note that Staff, the Intervenors,
and numerous customers expressed serious concerns about the
Company's business practices particularly around the Company's
dealings with related entities. It should be noted that the Commission
had three categories of concerns that had general applicability across
se veral areas. First, the Commission belie ves that it is necessary to
reiterate what we stated in SWS-W-23-02, Order No. 36816: 'If the
Company belie ves the[appro ved rate]is too low, we remind the
Company it is the Company's not Staffs or the Commission's—
responsibility to support its proposed increases with accurate, itemized
and verifiable cost information."Order No. 36816 at 7. In this case, the
Company again failed to pro vide sufficient information to justify se veral
of the expenditures it may have otherwise been allowed to recover. The
Commission must base its decision on the record before it and if the
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 40 of 52

record does not support the Company's position, we cannot grant the
requested relief.
Second, the Commission notes that Staff, the Intervenors, and
numerous customers expressed concerns about the Company's
relationship with related entities. The Company suggested that Staff
made recommendations outside of the Commission's jurisdiction and
treated the Company's relations with these related entities in an
inconsistent matter. Specifically, the Company argued Staff accepted
the benefits available to the Company's customers from related entities
but rejected additional costs as imprudent. The Commission notes that
rate making and prudence determinations are a tenant of its statutory
duties Choosing to charge customers a premium when the Company
could seek market based transactions which would benefit customers is
a choice made by the Company and its related entitles. Absent
supported documentation on the record, we will not allow exaggerated
costs to be passed to customers. Unsupported related entity
transactions are not prudent, and it is not beyond our decision-making
authority to scrutinize them or disallo w recovery. While the Commission
will make its own determinations, when determining the prudence of
related party transactions, it is routine for Staff to recommend that
customers should be able to utilize the benefits of such relationships
where available but not be subject to excessive charges. The
Commission's standard for recovery for a related party transaction is the
lessor of the actual cost or the market rate. Bolse Water Corp., 97 Idaho
at 837. The Commission believes that decisions in this case are
consistent with the intent and spirit of the Boise Water decision and our
past decisions.
The Supreme Court also noted that `charges arising out of intercompany
relationships between affiliated companies should be scrutinized with
care . . . and if there is an absence of data and information from which
the reasonableness and propriety of the services rendered and the
reasonable cost of rendering such services can be ascertained by the
commission, allowance is properly refused.N Boise Water Corp., 9 7
Idaho at 837, citing Solar Electric Co. v. Pennsylvania PUC, 137
Pa.Super. 325, 9 A.2d 447,, 473(1939). Frankly, the Company's
relationships with its related entities have clearly demonstrated the need
for this additional scrutiny. The Company's argument that it is Making]
advantage of Esprit's resources without adequate compensation"is an
illustration that Stonendge does not understand its duties to serve
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 41 of 52

customers at fair,just, and reasonable rates over its relationship with
related entities. Reply Comments at 43. We expect Stoneridge to seek
the best deals for its customers;its unsubstantiated complaint that it is
not paying more illustrates the problems of these related party
transactions, If the Company feels that the Commission is not treating
these related party transactions like regular arms-length transactions, it
is incumbent upon the Company to demonstrate that the transactions
are fair,just, and reasonable when compared to the broader market.
Third, it is the Company's burden to provide sufficient evidence to justify
its requested rate increase. In many instances the Company has failed
to provide sufficient evidence to justify the expenses it seeks recovery of
now. Can the Company remedy this looking forward?Possibly
depending upon the quality of evidence it submits. The decision made in
this case relates to the record before the Commission. Page 30-32
December 24, 2024
10.IPUC Discussion of Customer Comments with Lack of Perspective
The Company has experienced a consistent pattern of Staff and Commission
seemingly fail to exercise their "dual duty" of representing both the Customer and
the Company in matters before the IPUC. In five years it has been readily apparent
that the Commission is captured by its seeing its most important mission to ensure
the Customers have low water rates to the point of ignoring the long-term impact
of operating the Company in a manner that will "Starve it" of sufficient capital to not
only run current operations safely and profitably but to also allow a 35 year old
utility system to generate the capital necessary to upgrade and replace its
infrastructure efficiently. As a consequence of this strategy the Company faces an
increasing amount of unplanned and budgeted significant capital investments in
Pumps, distribution lines, Water Storage Capacity along with backup power
systems not included in the original system design/buildout. An example of this
blatant bias on the part of IPUC is no better highlighted than by the inclusion of
Customer comments regarding the integrity of Mr. Karupiah and his business
practices in the Commission Order. We would like to know which Staff member
thought it appropriate to include in the public IPUC Comments/Report the
completely undocumented claim that Mr. Karupiah and his interests have been
using water from the Company's unmetered fire hydrant for their own use. Does
IPUC feel that incredibly biased and totally undocumented Customer claim
comment repeated by IPUC does not reflect an underlying favoritism towards the
Customer over the Company? Especially when no one at IPUC ever discussed the
issue with the Company prior to including it in a Public Document?
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 42 of 52

Commission Order
Many customers were also concerned about the sufficiency of the
Company's backup system during an electrical outage. Customers noted
that a recent fire in the area had resulted in an electrical outage which
also resulted in a water system failure. The customers were highly
concerned o ver the potential of fire hydrants, and other water fixtures, not
being able to work in a future potential fire-thus endangering the
customer's property and safety. Many customers were also concerned
about the low water pressure due to the gra vity fed system.
Many customers expressed concerns about the integrity of Mr
harupiah and his business practices Specifically, several customers
expressed concems about the relationship between the Company and the
related entities Some customers expressed concems that the owner was
using unmetered water fire hydrants for personal use and/or the use and
benefit of his related entities Page 29, December 24, 2024
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 43 of 52

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Attachment A—Attached to Email
IPUC Annual Reports 2001-2023
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 44 of 52

i

Attachment B
Memorandum of Jeff Merkeley regarding phone
conversation with Pat Eberlein, Commercial RE Broker
On ground lease rental rates
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 45 of 52

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Memorandum
Date: December 19, 2024
From: Jeff Merkeley
RE: Annual ground lease rates Analysis
I spoke with Pat Eberlein of Kiemle Hagood Commercial RE brokers office
in Coeur d' Alene Idaho this morning on the phone regarding market annual
lease rates for ground in the StoneRidge Golf Community.
Pat suggested the typical analysis is to determine the market value of the
land and use an 8% annual yield on that value to calculate the lease rate.
In StoneRidge the three (3) acre reservoir lake used by the Water Company
for Water Storage the `highest and best use"would be for development of
Golf Course Front Residential Lots. County zoning allows lot sizes down to
less than 6,000 square feet.
Three acres is 43,560 SF x 3 = 130,680 gross SF. Common area would
require approximately 30% or 39,204 feet leaving a net developable lot
area of approximately 91, 476 SF. 91,476 divided by 6,000 sf/lot would
yield approximately 15 residential lots.
Currently fully developed residential lots are being bought/sold in
StoneRldge for $125,000 each. The raw land value for the undeveloped
land would be approximately 22% of the finished lot value or $27,500 per
lot.
$27,500 per lot times a lot yield of 15 lots from the 3 acres would be
$412,500 in total raw land value in its current state.
Assuming an 8% annual return rate, the raw land would rent for $37,500
annually or $3,125/monthly.
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 46 of 52

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Attachment C
Insurance Premium Updated Quote
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 47 of 52

■ '0=
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[e-mail]
From: Scott Kanemoto <[e-mail]>
Sent: Friday, December 20,20241:47 PM
To: [e-mail]
Cc: Ashley Lehi
Subject: Water Treatment Premium
Chan,
If we take the total premium on the property and allocated the proportionate share of property coverage to the water
treatment buildings plus the general liability premium,the annual premium is$8,605.
Let me know if you need anything else.
Thanks,
Scott Kanemoto,CIC
Vice President I Broker
[e-mail] I crestins.com
c. [phone] 1 d.[phone] 1 f.[phone]
275 S.Main St.,Suite 100 1 Longmont,CO 80501
2000 S.Colorado Blvd.,Suite 11100 1 Denver,CO 80222
CRES
Click here to upload files.
CA dba Crest Insurance Agency License#OM96244
CONFIDENTIALITY NOTICE The information contained in this communication, including attachments is
privileged and confidential. It is intended only for the exclusive use of the addressee. If the reader of this
message is not the intended recipient, or the employee or agent responsible for delivering it to the intended
recipient,you are hereby notified that any dissemination,distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us by telephone
immediately.Thank you.
1

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Attachment D
Integrity Management 2024 Invoice Analysis
Integrity 2024 Contract Expense
JGM
12-Dec-24
2024
Month Invoice Amt.
April $ 3,765.24
May 4,521.52
June 3,552.93
July 4,415.53
August 4,826.89
September 4,375.71
October 3,573.70
November 3,581.07
Total 8 Months $32,612.59
Monthly Average for 8 months $ 4,076.57
Annualized Amount $48,918.89
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 48 of 52

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Attachment D
Inte-gri1y Management 2024 Invoice Analysis
Integrity 2024 Contract Expense
JGM
12-Dec-24
2024
Month Invoice Amt.
April $ 3,765.24
May 4,521.52
June 3,552.93
July 4,415.53
August 4,826.89
September 4,375.71
October 3,573.70
November 3,581.07
Total 8 Months $32,612.59
Monthly Average for 8 months $ 4,076.57
Annualized Amount $48,918.89
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 48 of 54

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Copies of Integrity 2024 Water Invoices
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 49 of 54

Integrity Water Management lr mice No. STRW 1120
PO Box 468
Athol,ID 83801
[phone] fax[phone]
INVOICE
CwtollName 8to erriidge Utilities a ... ...... .......... . .. W ......... Date 4/30/24 ....W..............
........................
Address 364 St�onerid a Road
City Blanchard State ID y ZIP 83804
Phone .......................................... ................._......................_
Description Unit PHa TOTAL
1- � Water System Management Services in April, 2024. $3,500.00 $3,500.00
1 2 2 his: After hrs turnoff @ customer's request, 127 Skyline,4/17. $75.00 $150.00
8 8 miles for system services from 4/1 to 8.* $0.67 $5.36
18 18 miles for system services from 4/7 to 13. $0.67 $12.06 .
53 53 miles for services from 4/14 to 20. $0.67 $35.51
83 83 miles for services from 4/21 to 27.** $0.67 $55.61
10 10 miles for services fron 4/28 to 30. $0.67 $6.70
i*Note that mileage Is not billed for routine travel to and from '
Stoneridge system during nominal business hours.
**Includes pTssure loss construction sample lab run to CDA.
$3,765.24
............................... .....
Payment Detail: $0.00
O Cash
Check w
O TDTAL $3,765.24
Due by the 10th of the following month. ww. _ •.wj
Balances over 30 da s will incur finance Office Use Only
~charges of]%per month.
Note that any mileage is b1hed at the RS approved rate of 67 cents per mile.

Integrity Water Management Invoke No. STRW 524
PO Box468
Athol,ID 83601
[phone] fax[phone]
INVOICE -
Customer
Name Stoneridge Utilities
..................................W. _. _ .w .... .... Date 5/31/24....._._...
Address 364 Stoneridge_Road ..............
City Blanchard State ID ZIP 83804
Phone
Dascrtption Ul t pesos TOTAL
1 Water System Management Services in May, 20Z4. $3,500.00 $3,500.00
1 Turn on service @ customer's request,48 Ironwood, on 5/2. $100.00 $100.00
1 Turn on service @ customer's request, 108 Ironwood, on 5/2. $100.00 $100.00 I 2 2 hrs:After hours emergency, main booster pumps failure, 5/4. $75.00 $150.00
1 Shutoff service @ 53 Lakeview on 5/22. $100.00 $100.00
1 Shutoff service @ 1 SS Skyline on 5/22. $100.00 $100.00 i
1 Turn on service @ 155 Skyline on 5/23. $100.00 $100.00
1 Turn on service @ customer's request, 84 Bunker, on 5/20. $100.00 $100.00
1 Turn on service @ customers request, 946 Chatwald, on 5/30. $100.00 $100.00
140 140 miles for services from 5/1 to 11.** $0.67 $93.80
24 24 miles for services from 5/12 to 18. $0.67 $16.08
70 70 miles for services from 5/19 to 25.** $0.67 $46.90 '
22 22 miles for services from 5/26 to 31. $0.67 $14.74
*Note that mileage is not billed for routine travel to and from
Stoneridge system during normal business hours.
**Includes lab run for construction samples,after hours booster
pump failure& reading meters.
.$4,521.52
Payment Details 0...
$ .00
Q Cash
10 Check
O TOTAL $4,521.52
Due by the 10th of the following month.
Balances over 30 days will incur finance Office Use Only
chi sr of 1%per month.
/Vote that any mileN° qe is billed at the IRS aAaraved rate of 67 cents per mile.

Integrity Water Management Irnoloe No. STRW 624
PO Box468
Athol,ID 83801
[phone] fax[phone]
INVOICE
c ustomw
Name Stoneridge Utilities _ W Date 6/29/24.........................
Address 364 Stoneridge Road
City Blanchard State ID ZIP 83804
Phone _...__.._.... .._._................. ........._...... .... .......... . .._......................._........ .................. .._.......................
'Q�y _ Dascr�tion Urlltpride TOTAL �
E w Water System Management Services in June, 2024. $3,500.00 $3,500.00
i 17 17 miles for services from 6/1 to 8. $0.67 $11.39
j 11 11 miles for services from 6/9 to IS. $0.67 $7.37
I 35 35 miles for services from 6/16 to 22. $0.67 $23.45
16 16 miles for services from 6/23 to 29. $0.67 $10.72 1
i
*Note that mileage is not billed for routine travel to and from
Stoneridge system during normal business hours.
..............$3,552.93
Payment Details $0.00
Q Cash
Check
O TOTAL $3,552.93
Balances over 30 da s will incur finance Office Use Only
charges of 1%per month.
Note that an 17uleage is billed at the IRS a roved rate of 67 cents per mile.

Integrity Water Management Involoa No. STRW 724
PO Box468
Athol,ID 83801
[phone] fax[phone]
/NVOICE
Cuatansr
Name _Stonerldge UtiLties _ Date 7/31/24
Address 364 Stoners Road w... .... . W........._.......................... .... .......................
City Blanchard State ID ZIP 83804
Phone
Dsuvintion tkft pica TOTAL.
I� 1 Water System Management Services in July, 2024. $3,500.00 $3,500.00
4 4 hrs:After hours power outage,reset pumps, fill reservoirs, 7/8. $75.00 $300.00
5 5 hrs:After hours power outage,well#2 failure on 7/21. $75.00 $375.00
19 19 miles for services from 7/1 to 6. $0.67 $12.73
107 107 miles forservices from 7/7 to 13. $0.67 $71.69
43 43 miles for services from 7/14 to 20. $0.67 $28.81
i 162 162 miles for services from 7/21 to 27. $0.67 $108.54
II 28 28 miles for services from 7/28 to 31. $0.67 $18.76
1
*Note that mileage is not billed for routine travel to and from
i Stoneridge system during normal business hours.
$4,415.53
...........................................
yawl rt Gawk $0.00
O Cash
Check
O T 'TOTAL $4,415.53
Due by the 10th of the following month.
- - W v
Balances over 30 da s will incur finance Office Use Only
charges of 1%per month.
Note that any mileage is bi/led at the IRS approved fate of 67 cents per mile.

Integrity Water Management kwolceNo. STRW 824
PO Box 468
Athol,ID 83801
[phone] fax[phone]
INVOICE
Name Sto endge Utilities =-ZIP83804
..........._.........._.............. Date 8/31/24Address 364 StoneridgeRoadCity Blanchard IP 83804Phone ...................._............._ _.. _......_.........W.....
..._-
i n Lk* TOTAL
1 Water System Management Services in August, 2024. $3,500.00 $3,500.001
2 2 hrs:After hours Well#2 failure on 8/4. $75.00 $150.00
3 3 hrs:After hours meter break @144 Homstead Rd(caused by $75.00 $225.00
customer)on 8/10.
2 2 hrs: 2nd meter break caused by same customer @ 144 $50.00 $100.00
Homestead on 8/12.
3 5 5 after hours:Meter break&temporary repair west of 178 $75.00 $375.00
Lakeview (NOT customer caused)on 8/17.
2 2 after hours: Post DEQ required pressure loss notices within 24 $75.00 $150.00
hours on all Lakeview properties on 8/18.
36 36 miles for services from 8/1 to 3. $0.67 $24.12
117 117 miles for services from 8/4 to 10. $0.67 $78.39 ,
131 131 miles for services from 8/11 to 17. $0.67 $87.77 I
I 172 172 miles for services from 8/18 to 24. $0.67 $115.24
13 13 miles for services from 8/25 to 31. $0.67 $8.71
3 1 _ Harvest Foods/Ace Hardware for meter repair parts on 8/12. $12.66 $12.66
-
$4,826.89
Payment Details $0.00
0 Cash
Check
O TOTAL $4,826.89
Due by the 1_Oth_o_f the following month. . W
Balances over 30 dap will incur finance Office Use Only
charges of 1%per month.
Note that any mlleagc is billed at the IRS approved rate of 67 cents per mile.

Integrity Water Management I1mbeNo. STRW924
PO Box468
Athol,ID 83801
[phone] fax[phone]
INVOICE
Customer
Name Stoneridge Utilities Date 9/30/24
Address 364 Stoneridge Road..... .» ....................» »..W.»_ . .....»... .».»..... ... ...................,............
City Blanchard State ID ZIP 83804
Phone
_ Description Ur t PMee TOTAL
1 Water System Management Services in September, 2024. $3,500.00 �$3,500.00
1 86 Ironwood turnoff on 9/27. $100.00 $100.00
1 Greensides irrigation meter tumoff on 9/27. $100.00 $100.00
i 1 Vineyards irrigation meter, building# 5 tumoff on 9/30. $100.00 $100.00
1 15 Fairway tumoff on 9/30. $100.00 $100.00 i
1 14 Fairway tumoff on 9/30. $100.00 $100.00
1 Vineyards irrigation meter#3 tumoff on 9/30. $100.00 $100.00
1 Vineyards meter, between buildings 4& 5 turnoff on 9/30. $100.00 $100.00
1 Vineyards meter, between buildings 1 & 2 tumoff on 9/30. $100.00 $100.00
21 21 miles for services from 9/1 to 7. $0.67 $14.07
' 15 15 miles for services from 9/8 to 14. $0.67 $10.05
52 52 miles for services from 9/15 to 22. $0.67 $34.84
25 25 miles for services from 9/23 to 30. $0.67 $16.75
$4,375.71
Payment Details $0.00
p Cash
Check
O »� TOTAL $4,375.71
Due by the 10th of the following month.
Balances over 30 twill incur finance Office Use Only
cha s of 1%per month.
Note that any mileage is b0led at the IRS a proved rate of 67 cents per mile.

Integrity Water Management Involos No. srnW 1024
PO Box 468
Athol,ID 83801
[phone] fax[phone]
INVOICE
Customer
Name Stonegd�e Utilities __..�._.._�....ww..- „w. w,, ,, Date 10/31/24......................
Address 364 Stoneri Road
City Blanchard State ID ZIP 83804
Phone .........................
' lint Ries TOTAL
�p..� Description
1mTm Water System Management Services in October, 2024. $3,500.00 $3,500.00
5 5 miles for services from 10/1 to 5 $0.67 $3.35
21 21 miles for services from 10/6/12. $0.67 $14.07
57 57 miles for services from 10/13 to 19. $0.67 $38.19
22 22 miles for services from 10/20 to 26. $0.67 $14.74
5 5 miles for services from 10/27 to 31. $0.67 $3.35
i
$3,573.70
.................................
Payment Details $0.00
0 Cash
19 Check ..�......
0 TOTAL $3,573.70
Due by the 10th of the followiM month.._ _------
Balances over 30 da s will incur finance Office Use Only
charges of 1%per month.
Note that any mileage is billed at the IRS aAwvved rate of 67 cents per mvye.

Integrity Water Management Imnoioel o. sTRW 1124
PO Box468
Athol,ID 83801
[phone] fax[phone]
INVOICE =
Customer
Name Stoneddge Utilities Date 11/30/24
_................. ... .. ...............�... ..W.....-... W. ... _................ .............................................
Address 364 Stoneridge Road
City Blanchard State ID ZIP 83804
Phone
Descrlptbn Lk t Puce TOTAL
1 Water System Management Services in November, 2024. $3,500.00 $3,500.00
21 21 miles for services from 11/1 to 9. $0.67 $14.07
24 24 miles for services from 11/10 to 16. $0.67 $16.08
62 62 miles for services from 11/17 to 23. $0.67 $41.54
14 14 miles for services from 11/24 to 30. $0.67 $9.38
I
i
Payment Details .............$3,58$0 00
.00
Q Cash
10 Check
0 TOTAL $3,581.07
Duey the 10th of the following month.
Balances over 30 da s will incur finance Office Use Only
charges of 1% r month.
Note that any mileage u b(Iled at the IRS approved rate of 67 cents periWle.

Attachment E
Rate Case Cost Amortization
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 50 of 52

-r-mr arm

a I
Attachment J
Rate Case Amortization
Exhibit 8 Rate Case Costs Amortization
Company Name:CDS StoneRld a Utilities,LLC
Idaho PUC Case Number: SWS-W-24-01
Test Year ended: 12/31/2023 Monthly_
Cost Per Months Total Months to Amortization
Sala %to Case Month to Case Cost Amortize Cost
JGM $ 3,000 30% $ 900 36 $ 32,400 30 $ 1,080
Becca $ 3,000 10% $ 300 36 $ 10,800 30 $ 360
Total Labor $ 6,000 $ 1,200 $ 43,200 $ 1,440
Other Costs
Mailing Costs $ 1,250 30 $ 42
Publication Costs $ 225 30 $ 8
Total Mail/Publish Costs $ 1,475 $ 49
Total Case Costs $ 44,675 $ 1,489

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Attachment F
Water Riaht Lease Rates
State of Idaho Water Rights Bank
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 51 of 52

11 . L
!m■sPI m-.L% ' vIgIPI -rd"

Jeffrey Merkeley <[e-mail]
Water Right leasing--any thoughts on what the going rate is?
3; ,sages
Jeffrey Merkeley<[e-mail]> Tue, Oct 22,2024 at 1:29 PI
ro: Luke Bates <[e-mail]>
we are working on a lease agreement with our parent company and is see 25.00 to$35.00/acre foot per year on the State Water Bank
pricing web page, would you have any
other places to find the current market information in the Panhandle?
thanks Luke!
Jeff
Jeffrey Merkeley
Technical Assistance Group
208-920-0442
[e-mail]
3ates, Luke <[e-mail]> Tue, Oct 22,2024 at 1:40 PI
ro:Jeffrey Merkeley<[e-mail]>
Mr. Merkeley,
From the Water Supply Bank literature, hftps:Hidwr.idaho.gov/iwrb/programs/water-supply-bank/pricing/ , I note FY2024
is $23.00/af and will increase to $33.00/af beginning in 2025.
1 recommend contacting Mary Condon who works directly with the water supply bank to gain particulars.
Contacts, Procedures, 8 Additional Info
Board's bank
Mary Condon
[phone]
[e-mail]
Regards,
Luke Bates
c- Water Resource Agent
Northern Region
P: 208-762-2817
IDAHO DEPARTMENT OF
_� WATER RESOURCES

Coeur D'Alene, ID 83815-7763
From:Jeffrey Merkeley<[e-mail]>
Sent:Tuesday, October 22,20241:30 PM
To: Bates, Luke<[e-mail]>
Subject:Water Right leasing--any thoughts on what the going rate is?
CAUTION: This email originated outside the State of Idaho network.Verifv links and attachments BEFORE you click or
pen, even if you recognize and/or trust the sender. Contact your agency service desk with any concerns.
[Quoted text hidden]
Jeffrey Merkeley<[e-mail]> Tue, Oct 22, 2024 at 3:54 PN
ro:"Bates, Luke"<[e-mail]>
Thanks for the info.
[Quoted text hidden]

Water Rights Wells - Streams/Dams/Floods - Forms - Water Data - Maps/Spatial Data - Legal - Board
About IDWR
Water Supply Bank Pricing
e Board establishes the price for renting water rights from their bank. Presently,the Board has established that the price
for water right rentals is$23/af through 2024 and will increase to$33/af beginning in 2025.An applicant may enter into an
agreement with a water right holder to negotiate a rental rate different than the Board's rental rate.Ten percent (10%) of the
gross rental fee will be retained by the Board for administrative costs of operating the Bank.The lessor (usually the water
right holder) will receive ninety percent (90%) of the gross rental fee as payment.There is no fee to submit a rental
application (https://idwr.idaho.gov/form/water-supply-bank/), only a fee once the rental is approved.There is a fee to submit a
Water Supply Bank lease application (https://idwr.idaho.gov/form/water-supply-bank/).
Local rental pool committees set the price,which the Board must approve,for water that can be rented from the rental pools
This price may be different for each rental pool and can be determined based on the location where the water is to be used.
For additional information, refer to the rental pool procedures listed on the Water Supply Bank's Administration page
(https://idwr.idaho.gov/iwrb/programs/water-supply-bank/adm inist ratio n/).
�dr -Te

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Attachment G
Non-Recurring Charges Reconnection Fee
31 Days or Greater
Corrected Renewed Petition to Reconsider SWS-W-24-01 Page 52 of 52

_ LA.Zmm�
0401 llcdm-l!lr'� XCIP
.gw -d.� m F-PA H

IDAHO PUBLIC UTILITIES COMMISSION
S h e e t 13 f"77
Approved Effective
Replacing all Previous Sheets
Per O.N.
CDS StoneRidge Utilities Secretary
RATE SCHEDULE
Schedule No. 1
Recurring Charges
Base Monthly Charges by Meter Size
Availability:
To all residential, multi-family, commercial and irrigation customers excluding bulk water sold to
contractors. Each housing unit is considered to be one (1) Equivalent Residential Unit (ERU).
Commercial ERU's will be estimated using a contribution to peak week calculation as can
reasonably be determined from actual usage or as estimated using IDAPA 58.01 .03.007.08
(Wastewater Flows from Various Establishments in Gallons per Day), or some other method
approved by the CDS StoneRidge Utilities, LLC, the Idaho Public Utilities Commission and
generally accepted engineering practices. Both the StoneRidge Timeshare Resort and Motor
Coach Village ERU's are currently covered under existing agreements that stipulate the
respective ERUs for their units.
Customer Charges:
Based on the cost of providing water service, and providing a Return on Investment the
minimum monthly charge with no water included are listed below by meter size.
Meter Size Minimum Monthly Commodity Charge Reconnection Charge (1)
.75 $24.00 $87.00 $.79/1K $2.94/1,000 Gal.(2) $65.00 $50.00
1.00 $24.00 $154.00 $.79/1 K $2.94/1,000 Gal. $65.00 $50.00
1.50 $96.00 $347.00 $.79/1K $2.9, /1,000 Gal $260.00 $50.00
2.00 $170.67 $616.00 $.79/1K $2.91 /1,000 Gal $462.00 $50.00
2.50 $266.67 $963.00 $.79/1K $2.9, /1,000 Gal $722.00 $50.00
3.00 $384.00 $1,386.00 $.79/1K $2.94/1,000 Gal $1,040.00 $50.00
4.00 $682.67 $2,464.00 $.79/1K $2.9411,000 Gal $1,849.00 $50.00
6.00 $1,536.00$5,546.00 $.79/1K $2.91 /1,000 Gal $4,160.00 $50.00
Notes
1. Minimum Monthly Rates are based on continuous service-i.e. 12 months per year.
Disconnect transactions (voluntarily or involuntarily) do not relieve the customer from
the obligation to pay the base Monthly Minimum Charge each month during the
disconnect period.
Issued by CDS StoneRidge Utilities, LLC
Issued Per IPUC Order No. Chan Karupiah, Managing Member, Director
Effective: P.O. Box 298, Blanchard, ID 83804
[phone]

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